United States Department of Agriculture May 30, 2018 Yu-Ting Guilaran, Director Pesticide Re-Evaluation Division (7508P) Office of Pesticide Programs, Environmental Protection Agency 1200 Pennsylvania Ave., N.W. Washington, DC 20460-0001 Re: USDA comments on the Preliminary Environmental Fate and Ecological Risk Assessment for Acetamiprid, Docket ID Number, EPA-HQ-OPP-2012-0329. Dear Ms. Guilaran: The United States Department of Agriculture is pleased to comment on EPA’s ecological risk assessment for acetamiprid, published in the Federal Register on February 27, 2018. Acetamiprid is a broad-spectrum cyano-substituted neonicotinoid insecticide used to control a wide variety of insect pests including sucking insects on more than 30 agricultural crops in the United States. In some crops, acetamiprid is a critical component of growers pest management programs, targeting control of multiple key pests co-occurring temporally (e.g., apple and pear) or in providing excellent control of insect vectors of viruses (e.g., celery and lettuce) that make produce unmarketable. USDA appreciates EPA’s expressed understanding of how the risk profile of acetamiprid differs significantly from the related class of nitroguanidine neonicotinoid insecticides, and requests that OPP risk characterization and risk management strategies take into account the most likely insecticide alternatives and adequately contextualize the risk-benefit balancing for acetamiprid in a comparative way to existing alternatives. USDA concurs with the conclusion on the low relative toxicity to bees (discussed below in taxa-specific comments). This makes acetamiprid an ecologically preferable option for growers of blooming crops to control problematic pest outbreaks at or around the bloom period—particularly on crops such as cotton, citrus, tree fruits, tree nuts, berries, cucurbits, and seed crops. USDA stands ready to work with EPA for questions in providing data input for risk assessments and the characterization of benefits for pesticide use that minimizes exposure concerns. Our detailed comments follow. Please let me know if you would like to discuss. Sincerely, Sheryl H. Kunickis, Ph.D. Director Office of Pest Management Policy 1400 Independence Avenue, S.W. Washington, D.C. 20250-0314 An Equal Opportunity Employer USDA comments on the Preliminary Environmental Fate and Ecological Risk Assessment for Acetamiprid, Docket ID Number, EPA-HQ-OPP-2012-0329: Ecological Risk Assessment Comments USDA acknowledges that the ecological risk assessment for acetamiprid included a good deal of helpful risk characterization information regarding the identified risks of concern. The assessment is well-organized, well-written, and logically organized in a way that presents risks estimates within an understandable context. USDA particularly appreciates the discussion of upper-bound Kenaga vs. mean Kenaga exposure estimates for foliar applications, exposure refinements for a likely shorter-than-default chemical degradation half-life, and dietary sensitivity analysis for terrestrial vertebrate exposure. These characterizations provide risk managers with useful and more realistic/likely field exposure scenarios for a number of non- target taxa across multiple acetamiprid use patterns. USDA further appreciates and supports the totality of effort and difficulty already undertaken by EPA in assessing ecological risks of the related class of nitroguanidine neonicotinoid insecticides. We appreciate the expressed understanding of how the risk profile of acetamiprid differs significantly from those chemicals, particularly with regard to pollinators. USDA herein offers some additional comments regarding the characterization of modeled ecological risks for acetamiprid and some additional discussion on the agricultural context of acetamiprid usage. General Comments on Agricultural Importance and Potential Risk Management Acetamiprid has significant benefit to growers as a broad-spectrum insect control option that is also quite safe to bees when used at typical agricultural use rates (i.e., rates that are not anywhere near highest labeled non-ag rates that drove potential uncertainties in EFED’s risk assessment). USDA concurs with the conclusion on the low relative toxicity to bees (discussed later in taxa- specific comments). This makes acetamiprid an ecologically preferable option for growers of blooming crops to control problematic pest outbreaks at or around the bloom period— particularly on crops such as cotton, citrus, tree fruits, tree nuts, berries, cucurbits, and seed crops. While USDA understands that acetamiprid is not a ‘zero-risk’ option for all non-target taxa, we urge EPA to consider the likely exposure characterization for those identified non- pollinator ecological risks of concern, and also to appreciate the comparatively low risks posed to bees when compared with nitroguanidine neonicotinoids, pyrethroids, organophosphates, and other broad-spectrum options currently used by growers. In this vein, USDA requests that EPA consider the benefits of acetamiprid prospectively (i.e., in light of possible mitigation decisions for other insecticides such as nitroguanidine neonicotinoids) and for EPA risk managers to think strategically in terms of overall risk reduction options within the ‘universe’ of available pest management options, rather than viewing acetamiprid risk-benefit considerations in a chemical- specific snapshot manner--particularly for blooming crops with exposure concerns for bees. USDA notes that acetamiprid was one of the primary alternative options cited by OPP in its assessment of the impacts of its Policy to Mitigate the Acute Risks to Bees from Pesticide Products (US EPA, 2017a, b, c). USDA appreciates that EPA considered differential grower impacts for a number of proposed implementation scenarios for this Policy. Ultimately, the Agency settled on a risk-driven policy (i.e., noting application rates and exposure) in the final proposal (US EPA, 2017a), which USDA supports. USDA notes that in developing this finalized policy, the availability of acetamiprid was of lynchpin importance for growers of blooming crops, due to both its relatively low risk profile for bees and its broad-spectrum target pest efficacy. OPP-BEAD determined that the continued availability of acetamiprid (and indoxacarb) under the revised policy would considerably reduce the likely impacts on growers of blooming crops, particularly for crops such as pome/stone fruits and berries, etc. (US EPA, 2017b). As such, EPA recognized acetamiprid as an important tool that should remain available for bloom- time usage (US EPA, 2017c). USDA supported this determination in development of this policy. Acetamiprid is likely to take on even more importance for growers in the future if significant mitigations are imposed on nitroguanidine neonicotinoids or other alternatives in ways that further limit the availability of those alternatives. USDA encourages EPA to be cognizant that some of the likely alternative insecticides to acetamiprid may pose different (or even comparatively greater) ecological risks, particularly for uses on blooming crops. USDA requests that EPA recognize that the high agricultural importance of acetamiprid must be considered as EPA develops any new or additional mitigation plans under registration review. Terrestrial Vertebrate (Bird and Mammal) Risks Treated Seed Exposure: USDA appreciates the characterization discussions around the differential risk estimates for potential bird and mammalian exposure to treated seeds. USDA notes that treated potato seeds (because they are large tuber slices and not true seeds) are too large for typical bird consumption and not likely to be a primary food source for birds. Generally speaking, USDA concurs that treated mustard and canola seeds are a plausible exposure pathway for acute risks of concern for birds, particularly passerines, based upon the toxicity endpoints presented in the risk assessment. EFED has provided some useful characterization around the risk estimates, to which USDA would like to add a few points. USDA appreciates the characterization of the relatively low level of seed consumption that would be required to trigger acute risk concerns, at <5% of bird diet for large birds and <1% for small and medium birds. While some available anecdotal information indicates that canola and mustard are not likely to be highly preferred by most birds, this is also likely to vary significantly by bird species, and there is information to substantiate that some passerine species do indeed forage on rapeseed/canola for a substantial part of their dietary intake (Perkins et al., 2007). USDA requests that EPA consider what information may be available and known regarding the potential repellence/reduced palatability of insecticide-treated seed relative to untreated seed. If treated seed is repellent or generally less palatable to most birds, this might be considered for additional characterization of risks for the passerine species that most commonly co-occur with areas of widespread canola and mustard seed production in the United States. EPA might also seek further information on the potential usage of bird repellant chemicals (for example anthraquinone, which was recently registered for Section 3 use on other grain crops) on canola and mustard seeds, as this could be another factor that would decrease the likelihood of exposure. USDA stands ready to assist with any additional information requests in support of such characterization. For mammals,